Although the CEQ regulations say little about purpose and need for agency actions, defining them clearly is very important.

A. Purpose

Purpose is a statement of goals and objectives that NPS intends to fulfill by taking action. These goals can come from a park’s statement of purpose and significance (if the action proposed is a GMP, for instance), from management objectives or mission goals, from implementing or other legislation, from a GMP or other plan, from standards and guidelines for a particular management zone, from public or staff input, and from other sources. Because some of these objectives also may resolve needs, there may be overlap between purpose and need. The discussion should be limited to those goals and objectives that are critical to meet if NPS is to consider the proposal successful.

B. Need

Need is a discussion of existing conditions that need to be changed, problems that need to be remedied, decisions that need to be made, and policies or mandates that need to be implemented. In other words, it explains why your park is proposing this action at this time. It may have elements you would otherwise include in a discussion of project “background.” There may be one or several needs that an action will resolve. Need is not a discussion of the need for NEPA or other regulatory compliance, but rather reasons why the park must take action at this time and in this place. Although CEQ describes it as “brief,” the discussion of need may require several pages. You have great latitude in defining your proposal’s purpose and need. How you define it will also define the range of alternatives (see section 2.7). If it is defined broadly — for example, “to improve the visitor experience at the north rim of the Grand Canyon” — the range of alternatives will likewise be broad. If it is very narrowly defined — for example, “to provide an extended experience for visitors at the north rim of the Grand Canyon by building a lodge” — you may have violated NEPA by making a decision before the NEPA process has been completed. Try instead to be realistic in identifying your park’s reasons for taking action, and also to create a range of reasonable alternatives in which environmental impact information and public involvement would be helpful — for example, “to provide an extended experience for visitors at the north rim of the Grand Canyon.”

Further Link:

Purpose and Need Statements: Some Fatal Flaws

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